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Strategies for Better-Informed Risk Decision Calls: HSBC on Proactive Russian Sanctions Analysis Investigations

05/31/23 4 minute read

Since Western nations condemned Russian aggression against Ukraine in March 2022, designated Russian entities have been heavily involved in evading sanctions and have introduced a continuous stream of new challenges for the financial intelligence units (FIUs) of major financial institutions.

To effectively mitigate counterparty risk in an increasingly complex global sanctions environment, bank FIUs must supplement proprietary bank data and watchlists with third-party sources and innovative analytic tools. By prioritizing certain types of information, HSBC successfully developed a proactive risk assessment program and mitigated a variety of financial crime risks stemming from the new Russia sanctions regime.

Watch now for a conversation with Patrick Dutton, HSBC’s US Head of Financial Crime Risk Assessment and Compliance Analytics, and Stephen Dennison, his lead analyst on sanctions evasion at Financial Crime Risk Assessment, on the data, approaches, and methodologies critical to proactively assessing Russian sanctions risk.

Patrick Dutton

Patrick Dutton

SVP, Financial Crime – Compliance, HSBC USA

Patrick Dutton is the U.S. Head of Financial Crime Risk Assessment and the U.S. Head of Compliance Analytics. He joined HSBC in 2017 and oversees proactive intelligence and analysis on financial crime. He is also responsible for managing the Bank’s BSA/AML and sanctions screening models in the United States, and associated AML and model risk controls. Prior to joining HSBC, he held several positions at the U.S. Department of Defense, U.S. Department of the Treasury, and served as the Director for Transnational Organized Crime at the White House/National Security Council from November 2015 to May 2017. Patrick earned a Bachelor’s degree in political science from Marietta College in 2002 and a Master’s degree in Public and International Affairs from the University of Pittsburgh in 2004.

Stephen Dennison

Stephen Dennison

SVP, Manager, Financial Crime Analysis – HSBC USA

Stephen Dennison manages the sanctions, geopolitics and trade portfolios on the U.S. Financial Crime Analysis team as part of HSBC’s compliance function. He is a Certified Anti-Money Laundering Specialist (CAMS) and has presented on sanctions evasion activity at ACAMS and American Conference Institute events.

Dennison joined HSBC in 2018 and conducts proactive intelligence analysis on emerging and evolving financial crime threats, fusing bank and commercially available data with open-source research. He has built expertise in the mitigation of geopolitical and maritime risk, as well as environmental crime.

Before joining HSBC, Dennison worked for 10 years in various intelligence roles at the UK Ministry of Defence. While there, he focused on counter-terrorism investigations and the disruption of terrorist networks. Dennison also worked on implementing innovative government intelligence information technology (IT) systems and the formulation of associated changes to working practices and policies.

Dennison earned a bachelor’s degree in history from University College London in 2004 and a master’s degree in international relations theory from the London School of Economics and Political Science in 2012.

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